General Data Protection Regulation GDPR

GENERAL REGULATION DATA PROTECTION (AVG)

The company Komfly - Onur Airbrokers, (hereafter "Komfly" or "we"), attaches great importance to the protection of your personal data and closely monitors compliance with the provisions on the protection of privacy and the processing of personal data, in particular the European regulation on the protection of individuals with regard to the processing of personal data and the free movement of such data (EU Regulation 2016/679 of 26 April 2016), the law of 6 January 1978 entitled "Computing and Freedom" amended in 2004, as well as recommendations of the CNIL (hereinafter the "applicable legislation").

The purpose of this Privacy Policy (hereinafter "Charter") is to describe how and when Komfly, as a data manager, collects, uses and discloses certain personal data (hereinafter "Data Protection"). Data that you send to them to meet your needs, but also to optimize and improve the quality of the services we offer.

1. In which cases does this policy apply?

2. What information is collected by Komfly?

3. How do we use the information we collect?

4. Which cookies are used by Komfly?

5. How long do we keep your data?

6. What are the categories of recipients of your data?

7. What is the legal basis for your data?

8. What are your rights?

9. Is your data transferred outside the European Union?

10. The protection of your data by Komfly.

11. Review of the Charter

1. WHAT CASES DOES THIS POLICY APPLY?

This charter informs you about how and when we collect, process and use your data:

* when you register on the Site by filling in various forms related to your account or loading Data;

* when you subscribe to a package stay;

* when you participate in a promotion;

* when filling in a questionnaire;

* when you contact our customer service.

This information may include, for example:

your name (s) and first name (s),

your date of birth,

your gender,

your mailing address,

Your email address,

your telephone number (s),

your payment methods,

your booking history.

The same applies to all information that you give us about people for whom you book a package. You agree to obtain their prior consent to communicate their data.

You can choose not to give us specific information; However, this decision can deprive you of part of the services and functions that we offer. Information that is essential for the delivery of our services and functions is indicated with an asterisk on our collective forms.

2.2 Data collected automatically

While browsing the Site, Komfly may, in strict accordance with applicable law and your rights, collect information regarding:

* the characteristics of the operating system, browser or devices (computer, tablet, smartphone) that you use to access our services;

* your location such as your IP address;

* your browsing history and your interactions with the content of the Site, such as the pages visited, the keywords used, the frequency of your visits to the Site, the advertisements you click.

3. HOW DO WE USE THE DATA WE COLLECT?

The browsing data is mainly collected through cookies. See article 4 for more information about these cookies.

3.1 Data from other sources

We may also collect data through third parties, including social networks, when you use the account that you have with these third parties to register or connect to our services. During this use you are aware of the Data that the third party sends to us.

We use, store and process your data to process your questions, manage our business relationship, optimize our services and tools to create and maintain a safer trust environment and to meet our legal obligations as we specify herein. -after.

3.2 Perform the contracts concluded between us

We use your data to facilitate the management of your subscription to a package stay and the implementation of the various related services.

Your data is used to collect your payments, to inform you by SMS, e-mail or any other means of communication about the execution times of the contract that binds us (information about your journey, possible delays in transport, extra services, etc. ).

As part of our business, we can use commercial partners whose mission is to provide certain services on our behalf.

For example, we do not have our own fleet of planes, trains or buses. We are therefore obliged to conclude contracts with carriers to take you to your destination. As a result, some of your information (last name, first name, date of birth, etc.) will be forwarded to the carrier (s) so that he can issue your ticket.

However, our business partners may not use your data for purposes other than those required to perform the services you have requested. Finally, they are obliged to treat them in strict accordance with the applicable legislation.

3.3 Give you access to the site and certain services

The information that you provide allows us to identify you in order to gain access to your account, which access is limited to verified persons.

3.4 Komfly news and personalized content

When booking a trip, creating your account on the Site or later, if you check the box or fill in the form that you can use to receive komfly news (product information and offers) and personalized content so that we can use your information to Communicate with you, depending on your preferences (including e-mail, text message, telephone or e-mail):

information regarding the site;

Invitations to Komfly events that may interest you

information about our offers;

information about charter updates or security measures.

You can object to the Komfly commercial communication at any time by (i) clicking on the link you log off or by following the opposition procedure indicated in these communications, or (ii) by contacting us such as described in Article 6 below. You can also object to telephone conversations.

We may also use your information to send you advertising messages that may be of interest to you on third-party sites or on social media platforms. For more information on this subject, we invite you to read the terms and conditions regarding the use of your data directly on these sites and / or third-party platforms.

3.5 For profiling purposes

We can also process your data as part of profiling operations.

Profiling consists of automated data processing that is designed to analyze, anticipate and evaluate your interests and preferences to send you personalized content and commercial offers tailored to your specific needs.

Komfly only shares your data with external suppliers to determine your profile and preferences more accurately and to send you more relevant content. In any case, Komfly will not pass on your data to commercial partners.

You can object to the use of your Data for profile purposes at any time by opening your Client account or by contacting us as described in Article 6 below.

3.6 Optimize the site and our services

We use your data for conducting investigations, technical tests (including anonymization of your data), deduplications, which enable us to improve and optimize the site and to adjust our tools and services. For example, it will ensure that the display of our different content is adapted to the terminal that you use, or allow us to host your data on even more secure servers, etc.

3.7 Processing claims

When you contact our customer service by telephone, via the contact form on the site or in any other way offered by Komfly (social networks, chat, etc.), we use your data (including record your calls with your prior permission) for :

answer you and offer a solution to your complaint;

take care of and follow up on your claim;

improve customer service.

3.8 For internal statistics and surveys

We may use your data to perform various statistical surveys and / or to ask you to participate in our own surveys.

3.9 Ensure compliance with the law and court decisions

Your data can be used for:

responding to a request from an administrative or judicial authority, a representative of the law, an assistant or a judicial decision;

ensure compliance with our terms and conditions and the Charter;

protect our rights and / or receive compensation for any damage we may suffer or limit the consequences thereof;

to prevent any action that is contrary to the applicable legislation, in particular in the context of preventing fraud.

4. WHICH COOKIES ARE USED?

4.1 What is a cookie?

When you use the Site, Komfly may place a file called "cookie" on your medium (for example a computer, tablet) via your browser. This allows you to identify your computer during your next visits during the registration period. So every time you visit the site, the details of your previous visit can be saved.

4.2 Which cookies are used?

Komfly uses in particular the cookies mentioned in the appendix of this document.

a) Cookies needed to provide the requested services

Komfly may use cookies that are strictly necessary to deliver the services or information you have requested, including:

cookies "session IDs to your customer account";

"shopping cart" cookies;

authentication cookies;

load balancing session cookies ("load balancing");

permanent cookies that adjust the user interface;

analysis cookies for viewing measurements ("statistical cookies").

Data collected by statistical cookies are not checked with other treatments (or previously anonymized) and are only used for the production of anonymous statistics.

These cookies do not make it possible to follow your navigation to other sites or to accurately locate you.

Certain cookies make it possible to analyze, optimize and personalize your navigation on the Site. They can also allow automated processing of your data in accordance with the terms and conditions stated in Article 3.4. These are only installed with your prior permission and explicit installation.

c) Cookies for monitoring and customization

During your browsing on the Site, cookies issued by third parties (communication agency, public measurement company, targeted advertising provider, etc.) may allow this during the validity period of these cookies.

(i) collect browsing information about the devices that view the Site, and

(ii) determine advertising content that may be of interest to you. The issue and use of cookies by third parties are subject to the cookie management policy of these third parties.

5. HOW LONG DO WE KEEP YOUR DATA?

In general, your data is only saved for the time required to complete the operations for which it was collected.

The different data retention periods have been collected here:

the data sent to us directly as set out in Article 2.1 are stored for the period necessary for their processing;

Navigation data is stored for a maximum of 13 months;

Prospect information is retained for a maximum of 3 years from the last contact you initiated with Komfly;

Data relating to the identity documents that you send to us when you exercise your right of access or rectification are stored for a maximum period of 12 months;

the information that takes into account the opposition rights of the persons involved to receive commercial prospecting is kept for a maximum duration of 3 years from the exercise of this right.

We can also remove your data from you on request.

At the end of the aforementioned periods, including your request for deletion, your data may be stored to meet our legal, accounting and tax obligations (for example: obligation to keep invoices for 10 years). year in accordance with the applicable limitation period and / or in contentious proceedings for the duration of the proceedings.

6. WHAT ARE THE CATEGORIES-RECIPIENTS OF YOUR DATA?

We can share your information with various third parties, including:

with our affiliated entities to provide you with the requested services or to act as a subcontractor in accordance with applicable law; our business partners, our suppliers and / or subcontractors who process our data on your behalf, according to our instructions, for the purposes specified in Article 2 (in particular transport companies, insurance companies, customs authorities, financial service providers, technical subcontractors, etc.). In particular, we ensure that these third parties offer sufficient guarantees to guarantee the protection and security of your data; to the duly authorized authorities, in particular in the context of legal proceedings or a request for information.

7. ON WHICH LEGAL BASIS ARE YOUR INFORMATION PROCESSED?

In accordance with applicable legislation, in order to process your data, we rely on various legal bases, and in particular on:

* your prior and explicit consent for the processing of your data for one of the purposes referred to in Article 3;

* the performance of the contract that binds us;

* the need to comply with a legal obligation or to defend us in the event of legal proceedings;

* the realization of the legitimate interest that Komfly pursues;

* protecting your interest.

8. WHAT ARE YOUR RIGHTS?

8.1 Your right to access, rectification, removal and opposition

You can ask us to view, correct, update or delete personal information about you.

You also have the right to object to the processing of your data.

8.2 The right to transferability of your data

The right to portability offers you the possibility to restore some of the data that you are interested in, namely:

* the data that you have sent us directly, as set out in Article 2.1;

* Data generated by your activities on the Site as described in Article 2.

* We will do our best to comply with your request within a reasonable period and in any case within the periods specified in the applicable legislation.

8.3 Define guidelines about the fate of your data

You have the right to set general or specific guidelines for storing, deleting and communicating your post-mortem data.

9. WILL YOUR DATA BE TRANSFERRED TO THE EUROPEAN UNION?

We may transfer your data to countries outside the European Union for the only purposes described in this policy.

For each of these transfers, we ensure that your data has a level of protection equivalent to that of Europe.

Transfer only takes place to countries recognized by the European Commission as an adequate level of data protection.

In the event that the data is transferred to a country that does not offer an adequate level of protection, Komfly and its partners or service providers undertake to control the transfer through appropriate guarantees (such as contractual clauses) that may be requested from us.

10. THE PROTECTION OF YOUR DATA

Komfly undertakes to guarantee the integrity and reliability of the data entrusted to it, in particular by taking all physical, organizational and logistical measures necessary to prevent alteration or destruction of such data, in particular by ensuring secure access only authorized to handle them.

11. REVISION OF POLICY

Komfly may need to change this policy, especially if current legislation changes. All changes are placed on this page. It is therefore advisable to visit this page regularly for any changes.